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4.2

A critical component of the digital investment management business model is the use of algorithms to automate the investment process. Accordingly, the FSRA sees a need to ensure that Digital Investment Managers have adequate algorithm and technology governance policies and processes in place to address the specific risks arising from such a technology-driven business model. The limited human interaction between Digital Investment Managers and their clients necessitates consideration of how suitability assessments are performed and the disclosures that are made to clients.